In its continued attempt to regulate every aspect of telecommunications, the FCC latest missive is a new Notice of Proposed Rulemaking (Notice) in Docket 24-213 seeking to improve the effectiveness of the Robocall Migration Database (RBD).
The agency created this Database in 2021 to implement provisions of the Telephone Robocall Abuse Criminal Enforcement and Deterrence Act (TRACED), which required voice providers to implement the STIR/SHAKEN caller ID authentication framework on their IP-based voice networks by June 30, 2021.
STIR/SHAKEN enables voice providers to verify that the caller ID information transmitted with a particular call matches the caller’s real number, which in turn helps to determine whether the call should be blocked or labeled.
Although the RBD has been in place for three years, the FCC recently found some problems that it could address:
We have identified deficiencies ranging from failures to provide accurate contact information to failing to submit robocall mitigation plans that in any way describe reasonable robocall mitigation practices. While the Commission has acted to support the integrity of Robocall Mitigation Database information by removing deficient filings through enforcement actions and remains committed to doing so, there may be ways that the Commission could incentivize providers to avoid submitting deficient filings to the Database in the first instance through additional procedural steps. (Notice, at para. 13).
Therefore, the Commission released the Notice and asked the industry to comment on the following proposals:
Proposes to amend its rules to require voice providers to update information they have submitted to the Commission Registration System (CORES) within 10 business days of any changes to ensure that the business name and address information automatically populated into Robocall Mitigation Database submissions from that system is current;
Proposes to require multi-factor authentication each time a provider accesses the Robocall Mitigation Database;
Seeks comment on requiring providers to obtain a unique Personal Identification Number (PIN) that must be provided before the Robocall Mitigation Database will accept a submission;
Seeks comment on requiring providers to remit a filing fee for submissions to the Robocall Mitigation Database;
Seeks comment on technical solutions that will scan Robocall Mitigation Database submissions, flag data discrepancies, and require providers to resolve such discrepancies before the submission is accepted by the filing system;
Proposes base and maximum forfeiture amounts for submitting inaccurate or false information to the Robocall Mitigation Database, or failing to update information that has changed within 10 business days, as required by the Commission’s rules;
Proposes to authorize downstream providers to permissively block traffic from Robocall Mitigation Database filers that have been given notice of facial deficiencies in their robocall mitigation plans and failed to correct those deficiencies within 48 hours; and
Seeks comment on additional procedural steps the Commission could require encouraging providers to submit accurate and complete information to the Robocall Mitigation Database and CORES and keep that information current.
The agency believes that the gains—including reduced fraud, avoided aggravation, and enhanced consumer confidence—will far exceed any added compliance burdens on voice providers.
The Commission also seeks comments on whether it should adopt additional procedural steps for Robocall Mitigation Database filings to improve and ensure the accuracy of information contained in the Database. These include requiring filers to update information in CORES, requiring multi-factor authentication functionality for the Database and whether to require providers to use a PIN to make filings.
Industry comments are due 30 days after the Notice appears in the Federal Register. Reply comments are due 60 days after the Notice appears in the Federal Register.
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